In my opinion absolutely no way to retrospectively penalise footballers for the image rights as whether they can get to a valuation or not, it’s so intangible that it’s hard for a court to levy a fine.
However the loophole should be closed off as it is a pisstake and morally wrong but every business in the land looks to offset its taxes as efficiently as it can. No doubt all these footballers just palm off finances to an agent and a accountant.